1993-10-18_REVISION - M1977378 (2)

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999 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH 'J 7 - ?j 78 ��of cow Dedicated to protecting and improving the health and � environment of the people of Colorado ✓ ; 4300 Cherry Creek Dr.S. Laboratory Building � / �.1 76 Denver,Colorado 80222-1530 4210 E.11th Avenue Phone(303)692-2000 Denver,Colorado 802 2 0-3 71 6 (303)691-4700 � ^ � Roy Romer r (`/' Governor October 14, 1993 Patricia A.Nolan,MD,MPH Executive Director Mr Allen Sorenson Reclamation Specialist Department of Natural Resources Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, Colorado 80203 0! / RE: American Tunnel and Terry Tunnel Bulkheads Sunnyside Gold Corporation CDPS No.: CO-0027529 and CDPS No.: CO-0036056 �p San Juan County Dear Mr. Sorenson: I have reviewed the September 23, 1993 submittal to you from the Sunnyside Gold Corporation regarding the installation of the bulkheads. The submittal describes proposals made concerning the water quality impacts of the bulkheads. From the submittal it appears to me that Sunnyside plans on going ahead with the bulkheads. A letter has been sent to Sunnyside from the Water Quality Control Division informing them that any new seeps, degradation in the quality of existing seeps or changes in the quantity of existing seeps would be considered a discharge without a permit. Therefore the Division is concerned with those elements proposed in the letter which addresses how such seeps would be addressed. The Water Quality Control Division has not been involved in the development of the seep study or the contingency plan, but does have concerns relative to the technical revision, in part as it may relate to respective program responsibility between the two Divisions. The Division feels that we can not make detailed technical comments at this time because we have not been party to the previous discussions nor have we reviewed prior submittals on this matter such as the plan to inventory the existing seeps/springs. We would be willing to review other related information and to sit down with DMG and Sunnyside and develop a plan which addresses both agencies concerns. In order to address our concerns and to ensure interagency coordination, it is suggested that either the technical revision be denied pending an agreement with the Water Quality Control Division on the plan and its inclusion into the present CDPS permits for the site or that the plan be approved with the contingency that an agreement with the Water Quality Control Division on the plan and its inclusion into the CDPS permits be reached prior to any plugging. Without such an agreement I am concerned that the agencies may send out conflicting messages.